Governing health and safety at lower tiers of the computer industry global value chain

Global brands remain under increasing pressure to ensure labor standards and codes of conduct are met by their suppliers. Yet little is known on how this is addressed by lower tier suppliers. This paper investigates whether, and how, occupational health and safety standards permeate down the computer industry value chain. We compare first and second tier suppliers located in Penang, Malaysia and their engagement with a private voluntary industry code - the Electronics Industry Code of Conduct, and the publicly regulated European Union Directive on the Restriction of Hazardous Substances. While these standards differ, we find the industry code absent at the lower tier, yet second tier suppliers do implement the European Union Directive. This is achieved without support from public agencies or inter-firm linkages from within the global value chain. Our findings question the emphasis placed on chain governance in the literature on labor compliance in global value chains, and suggest that alternative approaches, including market access linked standards, may be required for effective labor compliance.